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Richard Scott Braun RN Oct. 12, 2015

1503 Inverness Road

Lynn Haven, Florida 32444

Shiccacal@yahoo.com

850-774-9563 Cell

US Department Of Transportation

Federal Aviation Administration

800 Independence Ave SW

Washington DC. 20591

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the reform act) and 

CFR Part 11, Richard Scott Braun, owner and operator of an Unmanned Aircraft Systems (UASs),

requests to be exempted from the Federal Aviation Regulations (FAR) listed below so that Richard Scott 

Braun may operate UASs commercially in airspace regulated by the FAA, as long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333.

I am Richard Scott Braun, a Florida resident, with a Florida Driver’s license. I also have a private 

pilot’s license (VFR SEL) and will be the PIC. All operations will be performed with the public’s safety and 

right to privacy safeguarded at all times.

As described below, the requested exception would permit the operation of light weight (less 

than 55 lbs. total takeoff weight) UASs under controlled conditions for commercial use by a certified 

private pilot thereby enhancing safety and fulfilling the Secretary of Transportation’s ( the FAA 

Administrator’s) responsibility to “establish requirements for safe operation of such aircraft systems in 

national airspace systems.” Section 333(c), of the Reform Act.
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The UASs that Richard Scott Braun will operate (The Phantom 3 Professional quad-copter and

Inspire 1 quad-copter) are rotorcraft weighing less than 55 pounds including payload. They operate at a 

speed less than 50 knots and have the capability to hover and move in the vertical and horizontal plane 

simultaneously. Both have an auto return to launch point when battery power is under 25%. The UAS 

will operate within the line of sight within a protected flight area as described below and at 200 feet AGL 

or less with an observer located close at hand as to make voice communication possible. These 

operations will not create a hazard to users of the nation airspace, public nor the environment.

I plan to operate a UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned 

aircraft (UA or Phantom 3) and a transportable ground station. The Phantom 3 is referred to as a quadcopter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven 

by electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s.

I also plan to operate a UAS, the DJI Inspire 1 system which is comprised of an unmanned 

aircraft (UA or Inspire 1) and a transportable ground station. The Inspire 1 is referred to as a quadcopter with a maximum gross weight of about 6.5 pounds. It is equipped with four rotors that are driven 

by electric motors powered by batteries. The UA has a maximum airspeed of 22 m/s.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, Richard Scott Braun, operator of Unmanned Aircraft Systems (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of 

designated UAS, provided such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the NAS.
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I Richard Scott Braun respectfully request the grant of an exception to the following specific 

sections of the Title 14 Code of Federal regulations allowing it to operate lightweight UASs for 

commercial use,

14 CFR 21, subpart H, 14 CFR 45.23 (b) 14 CFR 91.7 (a), 91.9 (b) (2) 91.103 (b), 91.109, 91.119, 91.121, 

91.151, (a), 91.203(a) & (b), 91.405(a), 91.407(a) (1), 91.409(a) & (b).

I Richard Scott Braun submits this application in accordance with the Reform Act , 112 P.L. 95 

331334, seeking relief from any currently applicable FAR’S operating to prevent Richard Scott Braun 

future commercial use of small UASs to operate in the national airspace system as described below. The 

reform Act section 332 provides for such integration of civil unmanned aircraft into our national airspace 

system as it is in the public’s interest to do so. Richard Scott Braun UASs meet the definition of “small 

unmanned aircraft” as defined in Section 331 and therefor the integration of these UASs is expressly 

contemplated by the Reform Act. Richard Scott Braun would like to operate its lightweight UASs prior to 

the time period by which the Reform Act requires the FAA to promulgate rules governing such aircraft.

The Reform Act directs the Secretary of Transportation to consider whether certain unmanned 

aircraft systems may operate safely in national airspace before completion of the rule making required 

under Section 332 of the reform Act. In making this determination, the Secretary of Transportation is 

required to determine which UASs do create a hazard to users of the national airspace system or the 

public or pose a threat to national security in light of the following:

 The UASs size, speed, weight and operational capability

 Operation of the UASs in close proximity to airports and populated areas

 Operation of the UASs within visual line of sight of the operator

Reform Act 333(a). If the secretary determines that such vehicles “may operate safely in 

National Airspace System, the secretary shall establish requirements for the safe operation in national 

airspace.

Richard Scott Braun UAS’s are rotorcraft weighing less than 55 lbs. and they operate at speeds 

less than 50 knots and have the capability to operate in the vertical and horizontal plane simultaneously. 

The UASs will operate only within the line of sight of the operator within a protected flight area and at 

200 feet AGL or less. These will not present a hazard to the national airspace nor the public.

The very small nature of these UASs combined with the safe guards presented below, will allow 

for the safe operation greater than that envisioned by Congress for the FAA to establish and by 

exemption allow commercial operations of UASs to commence immediately. Also due to the size of 

UASs and the areas and altitudes they will operate approval of this exception presents no national 

security issues and absolutely minimal safety concerns which have been mitigated through my rigorous 

risk management process. Given the clear direction given in Section 333 of the Reform Act, the authority 

contained in the Federal Aviation Act, as amended, the strong equivalent level of enhanced safety, 

reduced emissions utilizing UASs verses traditional aircraft as well as the economic impact of greatly 
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reducing the cost of aerial photography thereby benefiting the greater public’s interest. Accordingly, I 

Richard Scott Braun requests that the FAA grant the requested exemption without delay.

The following will be considered as the binding limitation on operations of Richard Scott Braun’s UAS’s.

 Flights will only occur in the daylight hours,

 Operator and crews will also conduct a risk assessment and discuss any additional safety issues 

identified by the client before conducting UAS operations,

 Safety to the public and property will be of the highest priority when conducting flight 

operations,

 The operator will post advisor notice around the controlled area,

 The operator will be trained and certified in the proper safety and operations of the UAS,

 The operator will have been trained in operation of UAS generally and received up-to-date

information on the particular UAS to be operated as required.

 Maximum total flight time for each operational flight will be 30 minutes,

 Operations will be conducted through the use of checklists to ensure safe, predictable, and 

consistent outcomes,

 Flights will be operated in the line of sight of the operator(PIC) and Observer,(VSO)

 Flights will be terminated at any time weather and wind deteriorate to “unsafe for flight” by 

manufacturers recommendations,

 The UASs will weigh less than 55 lbs.,

 Flights will be operated at 200 feet AGL or less,

 Flights will be terminated at 15% battery power reserve.

 Crew will be at a minimum of operator (PIC) and an observer and/or camera operator (VSO),

 Operator and crew will remain in contact during the flight operation,

 The operator will perform a check of the flight area and make certain of the safety of all persons 

in the area.

 Consent will be obtained from all persons within the video capabilities of the units to further 

reduce the chance of violating anyone’s privacy.

 All required FAA clearances will be obtained and distances from airports strictly observed.

 All UASs will have the capability to return automatically to the operator in a safe manner with 

the auto return function checked and working.

 Flights will only operate in VFR conditions.

 UASs have a function on the control to tell operator the distance away from the operator and its 

battery power remaining.

 Flight team will communicate by voice and the use of two way radio if the area is too big to hear 

voice from all team members.

 When operating over or near water the UASs will be equipped with flotation devices so that 

recovery can be made as to prevent lithium battery exposure to the water table.

 Flights with be operated with a minimum lateral distance of 50 feet from any inhabited 

structures, buildings, vehicles, vessels or people not associated with the flight operation. 
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14 CFR part 21 Subpart H: Airworthiness Certificate 14 CFR 91.7(a), 91.203(a)(1) Subpart H, 

entitled Airworthiness Certificates, sets forth requirements for procurement of necessary certificates in 

relation to FAR 91.203(a)(1). The size, weight and defined area of operations for Richard Scott Braun

UASs flights permits exception from Part 21 because they meet an equivalent level of safety pursuant to 

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 USC 4470(f) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UASs from airworthiness certificates in consideration of 

weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. 

Richard Scott Braun meets or exceeds each of these elements. As of March 23, 2015 the FAA has stated 

that it will automatically grant a “blanket” COA for flights at or under 200 AGL to any UASs operator with 

a section 333 exemption.

14 CFR 91.203(a&b) provides for carrying of civil aircraft certifications and registrations. These 

are inapplicable for the same reasons stated above. The equivalent level of safety will be achieved by 

maintaining such certifications and registrations at Richard Scott Braun’s home office. 14CFR91.7 (a) 

prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be 

applicable in the form contemplated by FAR’s this regulation is inapplicable.

14 CFR 91.9(b)(2) Civil Aircraft Flight Manual in Aircraft 14 CFR 91.9(b)(2) requires an aircraft 

flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UASs this 

regulation is inapplicable. An equivalent level of safety will be achieved by maintaining such 

certifications and registrations at Richard Scott Braun home office. The FAA has previously issued 

exemptions to this regulation in Exemptions No’s 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167,

10167A, 10602, 10700 and 32827.

14 CFR 91.119 Minimum safe altitudes, prescribes safe altitudes for operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. I Richard Scott Braun will only 

operate its UASs at or below 400AGL. They will be operated on a well-defined area that has been 

carefully reviewed for hazards and minimizes the presence of any persons not essential for these 

operations. Flights will only be over private property that the owner has consented and all persons 

within this video area also give consent for this filming. Compared to flight operations of conventional 

and traditional aircraft or rotorcraft weighing far more than 50 lbs., operating below 500 AGL with 

flammable fuel UASs operations present a far smaller risk to the public.

Approval of these 333 Exemptions allowing commercial operations of small UASs in the service 

of aerial photography will greatly enhance safety by reducing the overall risk associated with traditional 

aircraft. Traditional aerial photography requires large aircraft with flammable fuel to fly in close 

proximity of populated areas and people in general. With the use of small UASs of 55 lbs. or less, battery 

operated and flying below 200 feet AGL the risk of injury of people on the ground or the crew has been 

reduced or almost erased.
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Granting Richard Scott Braun the above exemption will allow for the expansion of UAS systems 

in to the future for the safe conduct of free enterprise and the enjoyment of the masses. Richard Scott

Braun respectfully requests the FAA grant its exception without delay. The FAA has the authority to 

issue the exemption sought by Richard Scott Braun pursuant to the Federal Aviation Act, 85 P.L. 726 

(1958) as amended (the ACT).

Sincerely

Richard Scott Braun RN

1503 Inverness Road

Lynn Haven, Florida 32444

Shiccacal@yahoo.com

850-774-9563